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#477885 - 01/03/06 09:38 PM AB 456 (Prepayment Penalties)
02bonne Offline
Platinum Poster
Joined: Nov 2005
Posts: 620
Just wondering if everyone saw this and if anyone had any opinions.... (This affects only state chartered banks.)

http://www.legis.state.wi.us/2005/data/AB-456.pdf

Here is Peg Lautenschlager's response....
http://www.doj.state.wi.us/news/nr102605_cp.asp

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#477886 - 03/28/06 04:37 PM Re: AB 456 (Prepayment Penalties)
02bonne Offline
Platinum Poster
Joined: Nov 2005
Posts: 620
What has everyone being doing to comply with this? I anticipate we will have to create yet another form for the customer to sign to indicate they decline the non-prepayment penalty alternative (if applicable).

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#477887 - 05/19/06 08:07 PM Re: AB 456 (Prepayment Penalties)
Nanwa Offline
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Nanwa
Joined: Oct 2001
Posts: 5,564
Clintonville, WI, USA
We got into a battle of sematics with the regulators, they called our late charges prepayment fees, and no matter what we said, that is what they wrote up. So, we dropped prepayment fees altogether.
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#477888 - 05/22/06 03:23 PM Re: AB 456 (Prepayment Penalties)
02bonne Offline
Platinum Poster
Joined: Nov 2005
Posts: 620
How on earth would they confuse a late charge with a prepayment penalty? Gotta love the WDFI...

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#477889 - 05/22/06 09:15 PM Re: AB 456 (Prepayment Penalties)
Beagles22 Offline
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Joined: Jan 2004
Posts: 3,626
State of confusion
I have avoided this one as we have no loans with prepayment penalties. At least we dodged one bullet...
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Going to church doesn't make you a christian any more that standing in your garage makes you a car.

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#477890 - 05/22/06 09:25 PM Re: AB 456 (Prepayment Penalties)
02bonne Offline
Platinum Poster
Joined: Nov 2005
Posts: 620
We had them, but we took them out as this just complicated everything. We may reinstitute if we run a teaser rate, but it's too cumbersome for a minimal prepayment penalty otherwise. We still charge them on commercial deals, but AB 456 doesn't apply to commercial.

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